Whistleblowing at HSBC
HSBC is committed to fostering a culture of corporate compliance and ethical behaviour. HSBC's Whistleblowing Policy is one aspect of the bank's overall approach to preventing and detecting misconduct and ensuring compliance with regulation.
We believes whistleblowing is an essential part of building and maintaining a culture of speaking up about potential issues and risks. The HSBC Australia Executive Committee recognise the importance of the whistleblowing program, which is a key element of our organisational culture.
HSBC encourages its employees, customers and associated parties to raise concerns or suspected wrongdoings through their normal lines of reporting and escalation. These channels include employee line managers, the bank's Human Resources department, the local and global Regulatory Compliance functions, or via the complaints and feedback page on HSBC Australia's public website.
While most cases can be resolved through the normal lines of reporting, there may be occasions where an individual feels that they are uncomfortable raising serious or sensitive, conduct related issues. In these instances, HSBC offers a dedicated channel for whistleblowing as an alternative way of raising concerns. As part of this service, external whistleblowers such as consultants, suppliers and third party providers are also able to contact members of HSBC Australia's Regulatory Compliance department directly.
Who is a whistleblower?
A whistleblower is a director, employee or contractor of HSBC (either in Australia or within the HSBC Group) who makes or wishes to make a report in connection to reportable conduct and where the whistleblower wishes to avail themselves of protection against reprisal. A whistleblower may or may not wish to remain anonymous.
In July 2017, HSBC Australia adopted the Australian Bankers' Association's "Guiding Principles – Improving Protections for Whistleblowers", in addition to other relevant requirements. The Guiding Principles are part of the ABA's Better Banking program, and ensures that all banks' whistleblower policies meet the highest standards.
A key amendment to this initiative expanded the scope of eligible persons who can report concerns under HSBC's Whistleblowing Policy. These persons now include individuals outside, but associated with the HSBC Group, such as suppliers, contractors, consultants, secondees, brokers, auditors and former employees.
What concerns should be raised?
Any person who becomes aware of any of the following matters or any deliberate attempts to conceal the following matters, may report them using HSBC's whistleblower reporting mechanisms:
- Dishonest conduct by a person or persons connected with HSBC,
- Fraudulent behaviour,
- Bribery and corruption,
- Illegal activities,
- Breaches of Commonwealth or state legislation, or local legal and regulatory requirements by any member of the HSBC Group,
- Unethical behaviour (either representing a breach of HSBC Code of Conduct or generally other serious improper conduct); and
- Unsafe practices, including endangering an HSBC employee or work-practice or where the health and safety of an individual is being endangered or the environment is being damaged.
How to raise a concern (HSBC's whistleblower reporting mechanisms)
HSBC is committed to ensuring its whistleblower channels are accessible. To achieve this, a range of options are made available. External whistleblowers (i.e. whistleblowers who are not HSBC employees) should contact HSBC's local Whistleblower Investigations Officer, who is the senior management member of HSBC Australia's Regulatory Compliance function responsible for investigating whistleblower concerns:
Head of Regulatory Compliance Australia
Level 36, Tower 1, International Towers Sydney
100 Barangaroo Avenue
Sydney NSW 2000
Telephone: +61 2 9006 5888 (request to speak with the "Whistleblower Investigations Officer")
Where a report falls outside of the whistleblowing scope, the reporting individual will be advised of the appropriate action to follow.